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EPANonrulemakingEPA-HQ-OPP-2018-0805

Petition Seeking Revised Testing Requirements of Pesticides Prior to Registration; Notice of Availability.

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National Cotton Council filings
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National Cotton Council filed 3 comments on this docket between Apr 9, 2019 and Apr 10, 2019. 39 other organizations filed here. The comment window closed 2681d ago.

What National Cotton Council filed (3)

Apr 10, 2019· Comment submitted by Bart Davis, Chairman, National Cotton Council (NCC)· EPA-HQ-OPP-2018-0805-0088

March 26, 2019 Office of Pesticide Programs Regulatory Public Document (7502P) U.S. Environmental Protection Agency 1200 Pennsylvania Ave.,NW Washington, DC RE: DOCKET ID NUMBER EPA-HQ-OPP-2018-0805 Dear Mr. Keigwin, The Georgia Cotton Commission appreciates the opportunity to comment on the petition from the Center for Food Safety to the Environmental Protection Agency requesting that EPA either initiate a rule making or issue a formal EPA interpretation for planted seeds treated with systemic pesticides. We feel that the EPA has fulfilled its requirements under FIFRA during the registration and re-registration process for pesticide products labeled for use and urges EPA to deny the petition for such action. It is obvious that the public does not realize the extent of EPA's rigorous review process with multiple risk assessments in assuring human safety and reasonable certainty of no adverse effects. The Georgia Cotton Commission represents the interests of Georgia's 3,900 cotton producers. Cotton production accounts for approximately one billion dollars to our state's economy and Georgia ranks second nationally in cotton production. Seed treatments are vital to the success of our producers. A viable seed is a form of an embryo, seed coat and cotyledon until conditions are met for germination. The Federal Seed Act recognizes that a seed is a living organism and that producers of seed should provide a level of germination and crop established from the planted seed. Once seed is planted the seed and the internal embryo are subject to various soil dwelling pests. This exposure results in planting seed being destroyed before germination. Research is proven that seed treatments both systemic and non-systemic provide numerous benefits and in some instances reduce the number of subsequent foliar applications. Science has recognized that it is critical to protect seed/seedling in order to achieve an adequate plant stand. Upstream seed treatment technology provides reliable application technology, reduces the need for field handling of products, provides quality assurance and reduces potential exposure to handlers and application errors ion the field. We urge the EPA to recognize the many benefits of seed treatments. without the treated article exemption our producers will incur increased costs for planting and additional record keeping and increased time if they are forced to use non-treated seed. We appreciate the opportunity to provide comments and encourages EPA to deny the petitioners request. EPA has complied with FIFRA and associated pesticide regulatory legislation. Any additional levels of regulatory action beyond the treated article do not provide justifiable benefits and would increase risks by forcing producers to abandon advanced, reduced-risk methodology of protecting seeds/seedlings for adequate plant stand emergence. We also fully support the detailed comments submitted by the National Cotton Council and have attached them for your reference. Respectfully, Bart Davis Chairman

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Apr 9, 2019· Comment submitted by James L Webb, Producer, National Cotton Council (NCC)· EPA-HQ-OPP-2018-0805-0045

Filed on regulations.gov — full text not in the inline record.

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Apr 9, 2019· Comment submitted by Reece Langley, Vice President, Washington Operations, National Cotton Council (NCC)· EPA-HQ-OPP-2018-0805-0065

Filed on regulations.gov — full text not in the inline record.

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Abstract

The petitioner, CFS, requests the agency either initiate a rulemaking or issue a formal agency interpretation for planted seeds treated with systemic insecticides. CSF believes that the agency has improperly applied the treated article exemption at 40 CFR 152.25(a) in exempting these products from registration and labeling requirements under the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA

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Co-filers (39)

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